ML20078A048
| ML20078A048 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/10/1991 |
| From: | Kennedy D MASSACHUSETTS, COMMONWEALTH OF |
| To: | Ericson R NRC |
| Shared Package | |
| ML18010B173 | List: |
| References | |
| NUDOCS 9109300113 | |
| Download: ML20078A048 (13) | |
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THE PUBLIC SCHOOLS OF DUXBURY egys
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TELiPHON( 1617) 924 b601 oF FICE oF THE SUPE ntNTE NDE NT June 10, 1991 Mr. Robert Ericson Pilgrim Offaite Emergency Preparedness Tack Force U.S.
11uclear Regulatory Commission Washington, DC 20$$$
Dear Mr. Ericsont This statement is in responce to the NRC Tark Force'n Draft Report for Comment entitled "Findingc on incues of Offoite Emergency Preparedness for Pilgrim Nuclear Powerd.
The School Committee requests that the statement be made part of the official record of the NRC Taok Force Public Hearing to be held in Plymouth, Mascachusettc on June 12, 1991.
- rirst, the School Committee underctands that NUREG 0654.J.12 providec:
"Each organization chall deceribe the means for regictering and monitoring of evacuees at relocation centero in nost area.
The personnel and equipment should be
- apable of monitoring within a
12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period all residento end transients in the plume exposure EP2 arriving at relocation centers."
On June 3, 1991, the Duxbury School Committee voted:
"%. a t in the event of a radiological accident at Pilgrim Nuclear Power
- Station, all Duxbury otudents and staff relocated from Duxbury to Needham High School (the current relocation center for Duxbury students ) will be monitored by portal monitors at the Needham High School (also referred to in Implementation Plans ao the " host school").
The School Committee also voted to make the following requesto:
1.
That Boston Edison Company provide two portal monitors to be kept at the Needham High School or at any other "hont ochool" that may be duignated for Duxbury studento or staff. With respect to thic request, we note that the Task Force suggested that portal monitor requiremento be determined based on a " ten ceconda per p e r s o n '-
fermu2a.
Using this
- formula, over ten hourc would be required to
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monit or the Duxbury school population with a single monitor..
The two monitors are requested in view of this fact. and with consideration of the poonibility of mechanical failure.
2.
That the Massachusetts Civil Defense Agency assign and train personnel to operate the portal monitors at the llo s t School.
3.
That all appropriate Implementation Plans be. revised to
- reflect, and provide, that the Duxbury school population will be monitored at the host school relocation sites.
The Duxbury School Committee believen that the above vote and requests comply with federal regulations and guidelines, including the NUREG-cited above.
In addition to this vote and requests, we take this opportunity to raise five other concerns and ask that they also be made part of the official record of the June 12th hearing:
1.
Vans for lisnuicapped Students The draft Task Force report (see page 2-138) inaccurately assumes that only 2 vans, and no
-lift vans. are required for handicapped students in the Duxbury schools.
We have attached a schedule which accurately assesses the t ransport ation needs for the Duxbury Public Schools.
In particular, you will note that the current requirement is for vans and litt vans, as follows: Alden School 1 lift van: Chandler School 6 vans with children's car seats: Jntermediate School 1 lift vant 111gh School 6 vens with children's car seats.
2.
Training The draft report notes (pages 23-44) that 349 Duxbury achool personnel required training and that as of February 26 1991 only
9 8 of the 349 persons had received training during the previous II conths."
The report also noted that "additionel training sessions for School Depa rt ment personnel had been scheduled for March 18-21 1991."
As of the current date. June h 1991 only 40% to 50% of those required have been trained.
3.
Transportation Officers The Committee is seriously concerned with the proposed
" interim" accignment of DECO employees as Area II Transportation Officers.
(Draft report.
s u c c e ' a )t u.
2-144 Trained transportation officers are essential to pages the evacuation of the Duxbury school population.
We do not bein ve th.
this critical need is met by "BECO voluntr e on an interim basis and not for more than a 4-6 mm th period."
We request that whatever personnel are required be ssigned on a permanent bania.
4..
Doce Reduction The draft report notes that "no realistic dose-redaction study had been performed for the-shelters in l
D ux b 'a ry " (pages 2-150) and that the "Stato plans do not contain e.pecific p r o c e d v e t'.
to guide officials who must decide whether sheltering or e' acus ton is the protective action. recommendation.
(Pages 2-150).
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Both to IA) pr6vidi guidance to those who must decide whether to shelter or evacuate, and (B) permit the Duxbury ochool staff to move the student body to the areas of each building that offer the greatest shielding factor. the School Commit t ee requests that a dose reduction study be performed on each school building which has been designated as an emergency shelter.
5.
LOA format We note that the " Tack Force did not review the new LOA format".
(Draft
- report, pageo 2-131).
The School l
Committee has done so.
and it is clear that the new LOA format effectively reduces the level of effective planning.
Among other things, the new format extends mob.ilization time to three hours, and delays evacuation.
According the NE Sil A P documents, this delay will greatly increase the poccibility of exposure.
Further, the new format omits the numbers of drivers that will be available, and thus maken it impossible to determine the actual number of buaseo that can be provided.
The Duxbury School Committee is grateful for the time and effort the Task Force has committed to reviewing the Emergency j
Preparedness Process for the Pilgrim EPZ.
We are hopeful that it i
vill continue with its efforts, and will resolve these remaining issues to insure that Duxbury school children will be properly protected in the event of an accident at Pilgrim.
Sincerely, h M1 G
,9 'n y
Superinten en( of Scioo s
for the Duxbury Schoo Committee DK/pc cc:
Affected parties t
- O Wellesley Italocation Center in its findinos, the tank force determined that the Jsnues pertaining to the relocation centers fall into two broad categorien -
(1) facilities and equipment and (?)
utaffing.
Staffing in the key word no !ar as the Wellenley Relocation center in concerned.
The liational Guard has repeatedly made clear that planning should proceed on the basis that the Guard will require a twelve hour response time.
Because of this, Wellesley does not rnent the standards for a functioning relocation.
The first ovacuees will arrive about eleven and a half hours befcre the National Guard --
and the Guard cannot possibly monitor all the evacueen in the thirty minu2.es remaining.
Over the pant few yearn I have identified the obvious problem of the National Guard renponne time to all the responsible parties.
I hand delivered the information to Chairman Carr of the NRC on Oct. 12, 1989, the day of the only recent almost-full scale training exercine.
In the exercine i t r.c i f, the NRC, MCDA and HFCo covered up the response time problem by giving the Guard neveral d(Ly1 (not nours) advance notice that they where to report to Wellesley
-on the morning of the 12th.
All of the responsible huthorition were aware of this, yet the FEMA annessment of the Exercice failed to identify the deficiency.
Why?
The An adminnion that the Wellenley receptic answer is simple cent er would be c.,mpletely unable to monitor the evacueen in the prcecribed twelve hourn (at least without neveral days advance notice) wold have precluded the NRC from making Jts critical finding of "reanonable annurance."
l Thin time the Tank Force listened to, acknowledged and identified and annenned the significance of this deliciency.
i 1n tnis r e s pec t.
they fulfi11 the requi rements at their l
narter: and if tney had ntopped here they would have 14e e n hero's today.
They would have done their ^j o b ; and tne result of their no 1inding would have been giving DECO 120 days to correct the nituation - or nnut down.
But in the tradition of the NRC, just doing your job inn nonestly protecting public health and safety, in never top priority.
The Top Priority, as alwayn, in protect the industry - never to shut it down.
Thus we have THE QUICK FIX - junt let Deco say it will do the job.
r BEco will now fill the void and handle monitoring and the other ntaffirus positiom asnioned to the National Guard.
Our knights in Shininy armor.....HFCO!!!, with the he1p of some MCDA workern from Port Devens (which ir about to close) and DFW workers from Arlington.
Tl!U QUICK PlX a ppe a r r.ni at a lant denporate attempt on the part of BECO to avoid part '> of the Tank Force Charter -
" Recommend Whether tne NRc snould Reconsider i t r, Reasonable Assurance Pinding," arni 11 tnere in no " rea son a bl e annurance" to set the 120 Clock.
By the end of Apri1 the Tank iorce had completed itn review, and had found that the National Guard ntatting of the Wellesley Reception conter did not meet federal reaulatory requirements.
To avoid setting the 120 day clock, the Task Force delayed issuing itn already completed report, told UCCo wnat it was unwilling to tell the public, and then gave itself and BEco extra time to find thi, obviously inadequate OL11CM PlX.
What are the problems with the QUICK iIX:
'Di% ElBEf f2.21G W TR0hL13 - USURPl NG STATE RESPONSIBILlT1D planning is the responsibility of the State and Lonal Authoritien.
The new director of MCDA, Dave Rodham, not only appears to be extremely competent, he has dinplayed a willingnons to do the job properly. Inde;_d Mr.
Rodham reccanized the cignaticance of the National Guard staltino problen and has been working on a realintic resolution to the de'ici6ncy.
He han identilied approximately 8S protennionaln with radiation backgrounds and is now in the process of getting them on board and under agreement to fill the vacancies the National Guard can not handle in a timelv manner.
To avoid setttnu tne 120 w/ :to:A, the NR aro HP n pushco aside a reasonable and acceptanic recolution tnat han alreaay been proposed by, and both then and and currt.ntly t :,
in process at, MCDA.
By :toing no, tney simply usurped the authority of the State.
The State want(d time to put into place a workable plan that would protect its citizens: neither DECO nor the NRC was willing to permit the State to do so. Lotting the State provide something that worked might mean setting the clock.
But if the clock were set, fixing the problems would finally Oij6 4;..
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Decome top priority - which would be a welcome change since BECO certainly hasn't made ! i >: i ng the probler.n a sianificant priority in the past.
Ilif M11MIU) RUl.QE 13X J'JiQhLDj; COtJ PLI CT OF J !JTEREST A United Statan Court of /.ppeals defined a conf l ict of interert (463 P.2d 600, 602) -
" Situation in which the regard for one duty leads to the disregard of another."
"The concept reiers to a clash between Public Interest and private pecuniary (finances) of the individual. "
It does not take a Harvard Law Degree to quickly understand the conflict here.
IlY41G' !TC9 RDJ11RyRR Nil.1 MgW 1 Dill QYRG' PRfliRD h9 mrni_tnrre nnd findfi comAminalnd Jr. a potential Law imit anainEt IECQ2 Rvnn' lECD r.mnl.nyrs Kil.1 kunW Xba.t honent monliRr.ing may wfll mellD 1he end 21 EilGr_iD.L innd 21 hir JQlh There is no double check to provide any assurance of of accuracy and honesty in monitoring; a total of two men are assigned to the three monitors at Wellesley.
The confljet of interest is clear; and the :u alt is the very real d a n t., e. that contaminated citizens will not be Identified ano decontaninated.
Till: TlilRD QUICE EILQlflDj: 1NADEQUATE STAPPING AT WELLESLEY HECO and the Task Force would like us to be]ieve that
'nry can replace 50 trained and disciplined military personne) by uiving two training seccions to 20 BECU employees, 16 DPW workers from Arlington and, if it hasn't closed, 4 MCDA employees from Port Devens.
Had Stormin'
!1orman know this, 1 am sure he could have ended Desert Storm in lecn than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Had we told Saddam the HECO boys were coming and sent him Pilgrim's track record, we could have had an total currender without a single bomb being dropped.
Incompence is far more frightening than a smart missile.
Let's compare what the BECO boys (with their 2 training
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i session) will be doing to the jobs that had been assigned to the tJat ional Gua rd.
Reception Center tJumber of IlEco and Iosition IJa t i on a l Guard friends COC Liason 1
O g,,
itadio operator /
- p. -
1 0
Moni torino/Decon Station Coordinator 1
1 Docimetry Coordinator 1
1 Docimetry col 1ector 1
0 Personnel Monitoring /Decon Group leader 1
1 Vehicle Monitoring /Decom 1
1 Group Leader m
M, '#y Portal operator 4
2 fn,b. there are now only 2 operators for J portal monitors)
Initial Monitor (handheld}
2 2
Personnel recorder 3
2 Personnel decon assistant 4
a secondary Monitor (Decon) 4 4
aunnera 6
4 Vehicle Monitor 12 10 Vehicle recorder 4
2 Venicle Decon Assistants 4
0 bO 32 What does tnis tr ea n ?
The most obvious problem is the portaj monitor operators.
We finally got the long-fought-tor third monitor, so that if monitoring got started at a reasonable titre it could be completed within the proscribnd 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
But now we don't have an operator.
Another example of Eleco planning expertise.
BEco finally provided Ihe third monitor; one would have thought that whoever at H 1'C o ;31anned the Quick Fi >: would have rememoered and provided a tnard operator.
More important, each portal monitor really l
snould have 2 operators, particularly in view of the conflict of interest issue.
So we're really short 4 men, not only l
- one, t.
The so-called Initial Monitors are really second - they are hand-held monitors that follow the 2/3 portal monitors and are supposed to locate the particular area of contamination on people who have set off the alarms (which are set by BEco about once a year) of the portal monitors.
)[
This very time consuming.
At a minimum, there shoulo be 2 initial monitors for aach of the ?/3 portal monitors; not two total.
(We're down 2 to 4 initial monitorn, and iour more men).
I should also point out that, at some time, thase two initihl monitors ace supposed to be used to monitor all al1 the handicapped people, babies and others who can't use a portal monitor.
There are over nine hundred identifled handicapped in the E l"Z.
At a bare minimum, at least two more initial monitors (and trained people to operate them) are needed.
Personnel recorders are supposed to takedown all the personal information that is required to insuren fami'y reunification.
With two recorders assigned to the tal monitors, and one more assigned to the handicapped, the flow will will be anything but rapid: and don't. torget that thin all has to be completed within the mandated I? hour time ttare Interestingly enough, Beco has assigned 10 people (a third of the total number of available personnel) to do Vehicle Monitoring, although no vehicle will be decontaminated until until atter the National Guard gets trero.
The p-iority of cars over people is intercating, to say the least, and it maken one wonder what the BEco boys have been trained to do.
Do they work overtime for a car wash?
w NO RADIO OPERATOR.
It is truly amazing'much time the Task Force, fCMA and the NRC spend talking about the importance at communication, when they then accept a QUICK FIX that doesn't even include a radio operator during the early and most crucial part of the accident.
Communication was an intearal part of the entire evacuation planning process.
Without a rad i o opera t.or, anyone that Wellesley was
%pposed to communicate witn now nan a communication "eficiency.
Even Tiiore amazing is that we're supposed to believe that the BLCO BOYS and triends were fully trained an two QUICK FIX training sessions MAY 14, and 16th.
In just a few short hours, they didn't learn just the job they were supposed to do, they learned everything there is to know about a relocation center -- they can monitor, register, and decontaminate anything, be it a car, mother, baby or quadraplegic.
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i Is there-a r.eed to say it ?
The QUICK FIX JS A 1-DISASTER.
All we are asking is that you do your job.
State as you 'id in the draft report that "the monitoring evaluation criterion (j.12) and the protective measure olanning ste:n.urd [10 CFR 50.47(b)(10)] h.a v e not been met "
and say so unequivocally.
It ', en easy ctatement to make; 1 have been saying it 19 h.
The NRC, FEMA and DECO -
you are all since April of in violation of NUREG 06S4 AND 10 CPR S0.47 by allowing Pilgrim to operate at above Si power withcut Emergency Planning in place.
The Quick Fix isn't a fix at all; and the list of problems with the Wellesley Reception Center goes on.
1.
The question is not whether you think you need an LOA to insure the cooperation of the Red Cross, even though the gaidelines in NUREG 0654 are clear that all' support groups must sign an agreement or signature page.
The real issue is that the Red Cross Congregate Centers don't even exist, and that the Red Cross has stated that it will not participate in your man-made disaster.
2.
The statement in the draft report that the third monitor is necded only in case one of the others br'aks is net quite accurate The third is needed to perform
~onitoring within the proscribed time.
3.
FEMA's guideline for sending contaminated injured to a " nearby" hospital would be fine it the transportation were provided (which it isn't), and i' we nad enough hospitals to handle the volume.
Collective-)
,nd using the numers that you have accepted, the thirte
.L pitals can handle 39 people in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
There ais & er 900 special needs people that have been identitled.
Chanceu are if any become contaminated, many will be.
A plume does not selectively ueek out only one or two people; it covers a vant area a ni t everyone in it.
Tnirty-nine people in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is just the Deginning.
4.
Relocation Centers, like all things in plannir must conf orm to common sense.
Reading your and BEco's justifications of ridiculous planning scenarios brings clare Donahue to mind acain.
Clare would listen to and read through all the foolishneus and bring it right back to reality with her now immortal quote; "And who will bring the towels'"
There are stil' no towels.
Q.{ -
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I DUXBURY SCHOOL PROBLEMS Plannina tor the Du>: bury Schools is st:11 placued with problems.
The majority were are created by mistakes in Area Il planning, or by a tailure to integrate Area 11 plans with local plans.
Tne statement that "no man in an island" is particularly pertinent when applied to planning.
It is not enough for each individual to do its own job to insure that the small section f or which he is responsible reflects the curatanding needs tor that particular portion of the overall plans.
Real success comes only when all of the co-dependent individual aspects are examined and the necessary dovetailing cr integration is tnen accomplished so that all the oitierent pieces car: be brought together.
Pero, many of the the needed individual plans have not rseen prcpor ly 42veloped, and very few or the individual piecer have onto !it together.
I.
'ack of Monitoring - Pernaps the most critical sh r'
'ing tor the schools is the lack of any plan for et e monitoring.
EL :G 0654 i.12. provides, in pertinent part:
5 orgcnit tion shall describe the means for
-e istering and monitoring of evacuecs at relocation onters in host areas.
The personnel and equipment should be canable of monitoring within about a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> perica all ri 'idents and transients in the plume ext.osure EPZ at rivina at relocation centers."
In the Draft Report the Task f'o r c e finds tne concept oI monitoring school children at reception centers (relocation center) acceptable.
In concept, 3 agree; but once again tne task torce missed the real point.
The student relocation
" tto s1;. Scbo_ oui" have no monitoring centere - the so-calleci capat?
isles.
It woulu oc ditricult to imanine a mer?
unio anc clear, vlalation et tne iunt-cated Na umG pr^
2n.
an aside, I snould note that, contrary to what i t, c
_n the task force draft report. the idea of " host schools" for the school population was not an option tirst presented or developed by thc state.
Rather it was another of BECO's ideas - "Let's keep numbers down at reception centers to hell with the kids."
Let's dispel'some of the myths that BECO has presented to
-justity this blatant violation of the NUREG monitoring requirement.
L. Precautionary Transfer.nf Schqq.1 Childrcn -
DECD has attempted to convince the world that the children will be moved out before any release occurs. As mignt be expected, there are a number of flaws in tnis BECO
" thinking" 1.
As I've already discussed, there are not enough buses to evacuate the entire school population [See Buses or Lack Thereof): and the "new LOA format" allows, and in nany cases actually creates, and creates a 3-5 hour delay time before any evacuation will even begin.
2.
Yet, according to NUREG 0654 a release tron Pilgrim could occur in 0-30 minutes.
B.
If tne children leave the schools and pass through a radioactive plume, while riding on one of the supposed buses, the buses will be contacted by radio and told to go to Wellesley.
1.
Given the length of time it will take to get the children on the busses in the first place, the likelihood of the passing through a plume is far greater than it should busses De.
lf they do, it is not a laughing manner - The buses offer less than 11 dose reduction, meaning that they might as well-be standing out in the open.
2.
What is worth at least a chuckle is-BECO's apparent confidence that the busses will be contacted.
During the only recent "almost full scale" exercise in October of 1989, the town of Duxbury lost all communication with tne buses very earlv.in the game.
Since neither FEMA nor the NRC acknowledge tnis tailure in the FEMA report reviewing the exercise, there is no way of knowing if the communication void has been or will be corrected.
By the way William Russell of the NRC was in Duxbury's EOC during the time the entire EOC was trying to " find" the buses Bill neither noticed nor reported this problem, although the busses weren't officially "found" until the next day.
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1 C.
-If the children have been contaminated th'ey will be sent to Wellesley to be monitored.
Here, again, there is a wide variance between reality and the BCCO " truth". Again as already discussed, Wellesley simply does not have the capability to monitor the nchool population within the proscribed 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time.
The reception conter can't even handle the non-school population within that time period.
The new suggestion that school monitoring will be solved by providing some " express-line" ignores (i)
- that there aren't monitr>rs to use in such a line, (ii) that the " QUICK FIX" doesn't provide any people to operate the
" express" monitor even if one should be found, and (iii) that monitoring Duxbury's students and staf f will take 3 0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />, l
not including the Marshfield students and staff who will be in the same express line.
As an aside, this is probably an-appropriate time to raise a related question.
Given the obvious length of time it would take to monitor children in Wellesley even if
' Wellesley had monitoring capabilities, why does the plan both
- with separate " host school" student relocation centers at i
all?
The "take-the-children-to-the-Needham_ host-schools-
- after-they're-monitored-in-Wellesley" concept will result in
-chaos.
Parent will be arriving Needham'to find their children are still at Wellesley.
Then, with their pre-or post-schoo? children, they'll arrive at Wellesley overloading a system that already is not equipped to handle the minimum population percentage (20%) requirements.
This can only result in bedlam - torseeable to all.
On whom do we pin the blame?
BCCo? MCDA? The state? FEMA? Or the-NRC?
They all-know; they are all aware;.and they have all-been personally informed.
CAN,THIS PLAW BE FIXED?
YES !!!
On June 3,- 1991,-the-Duxbury School Committee June Jrd
.1991 voted:
That'in the event of a radiological accident at Pilgrim Nuclear Power Station, - ll Duxbury students and-a staff relocated from Duxbury to Needham (the current relocation center for Duxbury student) will be monitored by-portal monitors at the-Needham Relocation Center (
also sometimes referred to as the " host school")
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'The School Committee also-voted:
1.
That Boston Edison Company provide two portal monitors to be kept at the Needham High School or at any other " host school" that may hereafter be designated for Duxbury students or staff; 2.
That.tt.a Massachusetts Civil Defense Agency assign and train the appropriate personnel in a number sufficient to operate the portal monitors at the Host School; and, 3..
That all appropriate I.P.'s be corrected and redrafted as required to reflect, and provide, that the Duxbury r.,.hool population will be monitored at the host school relocation sites.
As a hidden " bonus" these two additional monitors could also be used to monitor parent and siblings who arrive in Needham to pick-up their children, and provide some needed relief to the overloaded monitoring system in Wellesley.
I discussed this " monitor-the school-children-in-Needham" procedure with-Chairman Carr, and his response to it was favorable.
Dave Rodham of MCDA has told me that to
-monitor the school children at the Needham-host school was feasible and realistic, and has given his word he will put the procedure in ' place.
If'the Task Force will face up to the inadequacy of the present plan, and support the relatively simple = solution, this is.one area in'which " reasonable assurance" may actua11y be provided
-II.
Other problems for Duxbury Schools - Unfortunately, the current: Jack of-monitoring plans or facilities is not tne only problem with the proposed emergency planning for the Duxbury Puolic: Schools.'
For example:
1.-Hand-held monitors: BECo has not delivered the handle-held monitors it promised the Scnool Superintendent.
Among other things these.are needed to back-up portal monitors in Needham.
2.? Training of teachers: Less than 50% of the teachers have been trained.
Perhaps this is an indication that the teachers meant it when, in response to a poll, they said tnat
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they would not participate.
- . Interim assignment of Transportation atticer.
Th i t is another part of the QUICK FIX.
As noted in the letter that the School Committee has submitted to the Tank Force, The Committee "is seriously concerned with the prope md
" interim" assignment of BECO personnel employeen as Area II Transportatien officers. (Draft report, page 2-144)
Trained transportation officers are essential to the successful evacuatin of the Duxbury school popu-lation.
We do not believe that this critical need in met by "BECo volunteers on an interim basis and not for mt_e than a 4-to 6-month period."
We request that whatever personnel are required be assigned on 1 permanent basis.
- 4. Dose Reduction:
As the School Committee said, a done reduction study should be performed on each school building that has been designated as an emergency shelter.
In the event of a fast breaking accident, current plans call for sheltering, not evacuating, the school children A dose reduction study is necessary (i) to provide guidance to those who must decide whether to shelter or evacuate, and (ii) if sheltering is the choice, to permit the Duxbury school staff to move the student body to the areas of each building that offer the greatest shielding factor.
- 5. The "new LOA format":
The new format, which the Tank Force did not review, severely diminishes the level of etfective evacuation planning for the schools.
The extende~
mobilization time delays evacuation to such an extent that the concept of " Precautionary Transfer of School Children" is joke.
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- 6. Misrepresentations of Host Schools:
The Task Ferce dratt report refera somewnat obliguely to the fact that, iust before the October 1989 exercise, it was discoverea that IWCo had misrepresented to the NRC that Framingham and Newton were the " host schools" tor Duxbury.
The Task Force treatment at this is another interesting example of its habit of relying on BECo for factual information, and avoiding public statements embarrasing to BEco.
The 1act is BEco LIED to the State, to Duxbury, to FEMA, and to the NRC.
Did you, the Task Force identify this violation of Title 18 Sec. 2001 to Mr. James Taylor, EDO as you were supposed to?
?
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7.
Camp Squanto:
Dr Kennedy and the Task Force again missed the point.
This is not a training problem; it is a problem in planning.
The children to which the Task Force draft report refers, including my son, fell through the cracks because BEco's planners, as they admitted in their Oct.
4, 1990 response to the NRC, could not comprehend that school and camps might run simultaneously.
Under BECo's plans, when schools are open, Camp I.P.'s will not activated.
The reverse is also true, as was apparent _ in Duxbury, last summer when the School wece not notified of an unusual event.
BECo planners have not yet figured out that all schools and all camps must be notified anytime that Emergency Planning is activated.
Remember, as NRC officials have taught me over the last four years, planning is simply "get them out and get them monitored".
Those two key issues have not yet been satisfactorily resolved for Duxbury's School Children.
What can the TASK FORCE do?
Recommend setting the 120 day clock - so the State will have the time, and BEco will finally have a real incentive, to fix the problems.
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